Examples of FSMA Corrective Action Plans in Practice

It’s now widely known that the Food Safety Modernization Act (FSMA) requires all applicable facilities to implement comprehensive corrective actions as part of a compliant food safety effort. What many corporate food safety managers may not know, however, is that developing a robust corrective action plan is about more than simply checking off your compliance boxes. Doing so actually strengthens your ability to reduce risk and protect your assets. For an inside look at how this unfolds, we’re bringing life to the practice of corrective action by offering you some tangible examples.

Based on FSMA standards, facilities have the flexibility to tailor preventive controls that address potential hazards in the foods they manufacture. These preventive controls must be implemented and monitored continuously. Should any problem implementing a preventive control be identified, it is the facility’s responsibility to correct it, reduce the likelihood the problem will recur, evaluate the affected food for safety and prevent that food from entering the market. These are corrective actions, and they must be planned thoughtfully and documented rigorously.

So, how can your company design a corrective action plan that not only meets these regulations, but also reduces the overall risk of experiencing brand-damaging, bottom line-depleting food safety problems and recalls? Here’s what you need to know.

Unifying the Contents of Your Food Safety Plan

Corrective actions are a significant component of your overall food safety plan. They operate in conjunction with the other elements to form a comprehensive strategy for risk reduction. If one or more of these factors is overlooked, the entire plan is compromised. A compliant food safety plan must include:

  • Hazard analysis: Identity known or reasonably foreseeable biological, chemical and physical hazards that may occur naturally, be introduced unintentionally or be introduced intentionally for economic gain. Here’s an example hazard analysis form:
example hazard form
  • Preventive controls: These must be written and implemented to ensure that the hazards will be significantly minimized or prevented and that the food is not adulterated. They include but are not limited to:
  • Process and operational controls that include parameters and values (critical limits)
  • Food allergen controls to address cross-contact and ensure proper product labeling
  • Sanitation controls to minimize or prevent environmental pathogens, employee handling hazards, and other risks

Once a facility has identified a preventive control for a hazard, it must make sure that the controls are being met. Here are some example forms for preventive controls:

example hazard form
example hazard form
example hazard form
  • Recall plan: If the hazard analysis identifies a hazard requiring a preventive control, the facility must have a written plan that describes the procedures to perform a recall of the product, including notifying consignees and the public, conducting effectiveness checks and appropriately disposing of recalled product.
  • Monitoring: Establish procedures to ensure that preventive controls are consistently performed, with appropriate documentation.
  • Corrective actions: Establish actions to identify and correct preventive control problems, reduce the likelihood of them recurring, evaluate affected food for safety, prevent that food from entering commerce and document all efforts thoroughly.
  • Verification: Implement activities to ensure that preventive controls are executed consistently and effectively to minimize hazards, with proper documentation.

Developing the Specifics of Your Corrective Action Process

To successfully carry out your food safety plan, every preventive control must be assigned adequate corrective action measures. For each one, it is essential to answer the following questions:

When a preventive control’s critical limit is exceeded:

  • What will be done to address the matter?
  • Who will be responsible for carrying out the actions?
  • Where will those actions take place?
  • When and how often will they be implemented?
  • How will you know if these actions are effective?
  • Who will be responsible for determining effectiveness?
  • How and where will records of said actions be documented?

For a clearer picture of how these questions play out in plan format, review the following model preventive control sequences for the processing of whole brownskin almonds, as developed by the Almond Board of California.

In order for any preventive controls program or corrective action plan to be successful, communication is key. Your team needs clear visibility into the non-conformances that are jeopardizing your food product at any stage of the process.

Ultimately, the only way to respond swiftly and appropriately is to rely on an automated solution that can immediately relay this information, send critical alerts and notify the right people at the right time. It’s the crucial link to strengthen every team member’s capacity to embrace corrective actions and process changes that protect consumers, maintain compliance, generate improvement and reduce overall brand risk.

Automating Your Corrective Action Plan for Proactive Food Safety

Corrective action and continuous process improvement are fundamental to meeting current FSMA regulations, but more than that, they protect your product, company, and brand from the risks of food safety problems and recalls. By embracing a sound system for leveraging positive testing samples and non-conformance data, you have the foundation from which to fortify your commitment to food safety and elevate your brand.

It is more important than ever to institute a data management solution that streamlines the data collection process across all channels. Arm your team with the tools they need to detect preventive control problems quickly and accurately, as well as respond and follow up effectively. An intuitive, automated data management and decision support solution makes this possible.

There is a critical juncture at which you need to assess your data to discern root causes and underlying issues in your process that can be addressed and improved upon. From operations and equipment to sanitation and human error, rely on the data to inform your decisions and actions. This is a crucial step in rectifying problem areas and minimizing the risks and costs associated with ineffective methods.

Utilize a solution that improves your ability to:

  • Communicate with key stakeholders and confirm the location of a positive result
  • Stop the operation of the implicated production line and determine the disposition of the product
  • Bring together critical components and people, as well as historical data, departmental or program data, etc.
  • Develop a flow diagram with inputs and outputs at each step, and map this to statements from the team on the floor and other activities at the plant in order to determine the source of the contaminant
  • Address the situation based on predetermined policies and standards or in relation to the root cause
  • Confirm, once corrective action is complete, that cleaning and sanitation was effectively performed through additional environmental testing
  • Use the team’s findings to improve processes, the overall environmental monitoring program, and plant operations
  • Document the incident, corrective actions and outcomes

A food safety software solution that meets and exceeds your requirements for compliant, effective corrective actions will be:

  • Specific to the needs of the food processing industry
  • Easy to adopt and use
  • Designed and developed on a cloud-based platform that is safe and secure (without necessitating significant IT infrastructure)
  • Open to exchanging data across other critical systems
  • Equipped with features for flexible scheduling, mapping, custom workflows, and reporting
  • Designed for collaboration, communication, and visibility for all required departments

To learn more about the processes and tools best implemented to solve corrective action challenges and reduce food safety risk in your facility, download this free guide now.

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